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CMS-1403-FC
Section 1848(n)(4) of the Act also permits us to focus
the program as appropriate, such as on physicians who use a
high amount of resources compared to other physicians. The
RURs disseminated in Baltimore and Boston contained
distribution curves that defined peer groups of physicians
for one condition using the specialty and geographic
benchmarks mentioned above. Within each peer group, a
physician was identified as a high cost outlier if he/she
fell within the 90 th percentile of cost or higher. In
addition, to including a high cost benchmark, the Baltimore
and Boston RURs included a low cost (10 th percentile)
benchmark and a median cost (50 th percentile) benchmark. We
are implementing this approach and welcome public comment
on the cost benchmarks, as well as any additional cost
benchmarks that could be included in the program. Further,
we are soliciting public comment on which benchmarks
(specialty, geography, and cost) are most likely to
motivate changes in resource use.
In order to identify a high cost outlier, attribution
of cost must be assigned to a physician. In the Baltimore
and Boston program sessions, CMS provided RURs that
contained several different methodologies for attribution
or assignment of costs to physicians. The following five
attribution rules were included: (i) physician billing the
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